區域貿易安排與所得稅差別待遇的消除：現行機制與未來路徑

Regional Trade Arrangements and Elimination of Differential Income Tax Treatment: Current Mechanism and Future Path

WTO多邊貿易體制和區域貿易安排並不干涉其成員的所得稅制度。然而，各國的歧視性所得稅措施和正常稅制所導致的差別待遇還是會對國際貿易和投資產生壁壘效應和扭曲作用。對於構成貿易壁壘的所得稅歧視措施，區域貿易安排沿用WTO的非歧視原則來進行規制；對於各國所得稅制所導致的差別待遇，區域貿易安排則借助國際稅收協定來處理。不過，WTO的非歧視原則和國際稅收協定的現行機制並不能徹底消除所得稅差別待遇，多達貿易體制和國際稅收協定都有進一步完善的空間。對於追求更高自由化水準的區域貿易安排來講，可嘗試其它新的機制。

The WTO regime and regional trade arrangements do not interfere with the income tax systems of their members. Discriminatory income tax measures and differential income tax treatment caused by the normal income tax systems of the members of regional trade arrangements do have distortive effects on international trade and investments. Regional trade arrangements coin the non-discrimination principles of the WTO regime to deal with discriminatory income tax measures which in fact are trade barriers, and take the advantage of double taxation conventions to deal with differential income tax treatment caused by income tax systems of their members. However, the WTO regime and the double taxation convention can' t thoroughly eliminate discriminatory income tax measures and differential income tax treatments. The members of regional trade arrangements, with the view to achieving further liberalization, should refine the trade regime and double taxation convention and try to design new mechanisms.